Case Summary (G.R. No. L-50283-84)
Procedural Background
• 1967–1977: Amigo Employees Union-PAFLU holds a collective bargaining agreement (CBA) with Amigo Manufacturing, set to expire February 28, 1977, containing a closed-shop clause.
• January 5, 1977: A minority group of employees files, through the Federation of Unions of Rizal (FUR), a petition for certification election. PAFLU opposes and the petition is withdrawn.
• February 7, 1977: The same minority executes a resolution disaffiliating themselves from PAFLU, declares the local union independent, and authorizes petitioner Villar to file for certification as an independent Amigo Employees Union.
• February 9, 1977: Villar files a petition for certification election; the Med-Arbiter dismisses it for lack of requisites and pending CBA.
Intra-Union Proceedings and Expulsion
• February 14–15, 1977: PAFLU convenes a trial committee under its constitution to investigate the petitioners for disaffiliation, libel, and sowing division.
• March 15, 1977: PAFLU’s national president renders a decision expelling nine petitioners (all except Felipe Manlapao) from the Amigo Employees Union-PAFLU and requests the employer to terminate them pursuant to the closed-shop clause.
• March 28, 1977: PAFLU denies petitioners’ appeal and formally demands the employer enforce the security clause.
Administrative and Judicial Actions
• April 25–29, 1977: Petitioners file a complaint with preliminary injunction before Regional Office No. 4 (RD-4-4088-77-T) to set aside PAFLU’s expulsion decision and enjoin termination. Amigo Manufacturing applies for clearance to terminate under union security (T-IV-3549-T) and places petitioners on preventive suspension.
• October 14, 1977: Officer-in-Charge of Regional Office No. 4 grants clearance to terminate and dismisses the preliminary injunction petition.
• February 15, 1979: Deputy Minister Amado Inciong affirms the Regional Office decision on certiorari review.
• Petitioners elevate to the Supreme Court, raising: (A) violation of freedom of association; (B) improper application of PAFLU’s constitution over local by-laws; (C) retroactive enforcement of the new CBA’s security clause.
Supreme Court Ruling and Legal Reasoning
- Closed-Shop Validity and Freedom of Association
– The Court reaffirms that closed-shop provisions are a valid form of union security and do not breach constitutional freedom of association under the 1973 Constitution. - Authority of Mother Union and Due Process
– By affiliating with PAFLU, the local union and its members become bound by PAFLU’s constitution and by-laws. Jurisprudence (Amador Bolivar v. PAFLU) treats the affiliation charter as an enforceable contract.
– The petitioners were duly notified, afforded opportunity to be heard, and thus received due process. - Intra-Union Dispute Exception
– The rule requiring exhaustion of local by-laws on intra-union disputes does not apply when the accusers constitute the very board that would judge the case, rendering the internal remedy illusory (Kapisanan ng mga Manggagawa sa MRR v. Hernandez). - Minority Action and Registration Defect
– Petitioners, as a minority, lacked authority to disaffiliate the local union; majority members remaine
Case Syllabus (G.R. No. L-50283-84)
Procedural History
- Petitioners filed a petition for review by certiorari before the Supreme Court, seeking to set aside the Order of Deputy Minister Amado G. Inciong dated February 15, 1979.
- The challenged Order affirmed the Decision of the OIC of Regional Office No. 4 dated October 14, 1978, which resolved jointly R04-Case No. T-IV-3549-T and R04-Case No. RD-4-4088-77-T.
- R04-Case No. T-IV-3549-T involved the Company’s application for clearance to terminate petitioners under the union security clause of the collective bargaining agreement (CBA).
- R04-Case No. RD-4-4088-77-T was petitioners’ complaint with application for preliminary injunction to restrain their preventive suspension and dismissal.
- Both cases were decided against petitioners by the Regional Office, and their appeal to the Deputy Minister of Labor was denied for lack of merit.
Statement of Facts
- Petitioners were members of the Amigo Employees Union-PAFLU, the accredited bargaining agent of Amigo Manufacturing, Inc., under a CBA expiring February 28, 1977.
- On January 5, 1977, the Federation of Unions of Rizal (FUR) filed a certification‐election petition on behalf of at least 30% of the employees; PAFLU opposed, invoking TUCP inter‐federation “Code of Ethics.”
- Petitioners then withdrew FUR’s petition and, on February 7, 1977, adopted a joint resolution disaffiliating themselves from PAFLU, revoking PAFLU’s authority in CBA negotiations, and declaring the Amigo Employees Union independent.
- On February 9, 1977, petitioner Dolores Villar filed a new petition for certification election in the name of the (purportedly independent) Amigo Employees Union. PAFLU-affiliated union moved to dismiss, alleging lack of valid disaffiliation, insufficient membership support, and pending case.
- PAFLU convened a special meeting on February 14, 1977, to investigate petitioners for acts of disloyalty and formed a Trial Committee. On the same date, PAFLU and the Company executed a new CBA reiterating the closed‐shop (union security) clause.
- Petitioners refused to participate in the PAFLU trial, demanded a bill of particulars, and later filed an answer. The PAFL